4A. Firm Description Springwater Wealth Management, LLC (“Springwater”) is a registered investment adviser. Springwater was established in 2013 by James L. Corbeau and Terence A. Donahe. Springwater provides financial planning, discretionary and non-discretionary investment management and wealth management advice to individuals, families and their related entities, trusts and estates, and family businesses on a fee basis as discussed at Item 5 below. These services are billed separately as unique services, as described below. Springwater also provides advice to retirement plan sponsors and their participants, and investment consulting services to retirement plan sponsors and trustees. Before engaging in any services, we will enter into an agreement specific to the services to be provided to you setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. The agreement may not be modified or amended without the written consent of both parties. The agreement may be canceled at any time by either party, for any reason, upon receipt of written notice by the non-canceling party. Upon termination, any prepaid, unearned fees will be promptly refunded and any earned, unpaid fees will be due and payable. 4B. Types of Advisory Services Springwater offers financial planning, investment management and comprehensive wealth management advice to our clients. Springwater also provides advice to retirement plan sponsors and their participants, and investment consulting services to retirement plan sponsors and trustees. All prospective clients receive a complimentary initial consultation to discuss the range and suitability of services offered. Financial Planning Springwater’s financial planning advice involves a range of services, principally advisory in nature, to assist you in developing strategies for the successful management of your financial resources in order to achieve your long-term financial goals and objectives. If you decide to retain us for financial planning services, we will:  define the scope of your initial financial plan with you  help you clarify and prioritize your financial and non-financial goals and objectives  collect, analyze and evaluate pertinent information about your current financial situation  develop and present to you a written financial plan  review with you the plan’s general and specific recommendations and action points The financial plan may, for example, recommend that you obtain new insurance or revise existing coverage; establish a tax-advantaged retirement account; consolidate several retirement accounts into a single rollover IRA account; increase or decrease cash holdings, or invest in appropriate securities according to an investment strategy based on your investment horizon, risk tolerance and other unique constraints. We may also suggest possible tax or estate planning strategies for you to pursue with an accountant or attorney. Financial plans are based on your financial situation at the time the plan is presented and are based on financial information disclosed by you to us. While we cannot offer guarantees or promises that your goals and objectives will be met, an advisory relationship with us can provide an ongoing stimulus to review, adapt and revise your financial plan throughout your lifetime. Proper financial planning is not a one-time event, and as your financial situation, goals and objectives, and the economic, legal and/or regulatory environments change, your initial plan should be revised to reflect these changes. Ongoing financial planning advice and periodic reviews can be accommodated in a variety of ways, depending on your needs. Investment Management The investment management advice and services provided by Springwater to our clients vary, depending on each client’s goals, objectives and other unique circumstances, including his or her investment horizon, risk tolerance and other constraints. Such advice and service typically include the design and implementation of a custom asset allocation, as well as portfolio monitoring, regular reporting, performance analysis and rebalancing recommendations. Your portfolio investment strategy will be initially designed to meet particular investment goals, which Springwater may help you determine, based on your circumstances. Once the appropriate portfolio investment strategy has been determined, we will periodically review the portfolio and, when appropriate, rebalance the portfolio, based upon your needs, stated goals and objectives. Springwater's investment strategy, generally, is to seek to meet your objectives at an acceptable risk level. Springwater asks our clients to give us discretionary authority to execute transactions without our client’s prior approval. These transactions may include the purchase and selling of securities, arranging for payments to the client, or generally acting on behalf of our clients in most matters necessary to the handling of the account. Wealth Management Our wealth management service integrates our financial planning and investment management services to provide you with a personalized investment strategy; portfolio management; risk management, tax and estate planning advice, and charitable and gift planning strategies. Our wealth management service is ongoing and consultative in nature, and we will meet regularly with you to review and update your information, measure progress in specific financial areas, and develop strategies to address changed circumstances. In providing wealth management services, Springwater typically works together with your other advisors, which may include your accountant, attorney, insurance agents and/or other professionals. These other professionals are engaged directly by you on an as-needed basis, even when recommended by us. Any conflicts of interest will be disclosed to you and managed in your best interest. Springwater Wealth Intelligent Portfolios The Springwater Wealth Intelligent Portfolios Program (the “SWIP Program”) is an automated investment management service available at our discretion to clients with smaller and/or less complicated investment and/or retirement accounts. Springwater uses the Institutional Intelligent Portfolios® platform (the “Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Charles Schwab & Co., Inc. (“CS&Co”), to operate the SWIP Program. Schwab provides technology and related trading services and automates key parts of the investment process. SWIP Program clients are invested in a range of investment strategies Springwater has constructed and manages, each consisting of a portfolio that can include exchange-traded funds (“ETFs”) or mutual funds, and a cash allocation. As a SWIP Program client you may instruct Springwater to exclude up to three mutual funds or ETFs from your account. Your account is opened by you at Charles Schwab & Co., Inc. Springwater is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co, or their affiliates (CS&Co and its affiliates are sometimes collectively referred to as “Schwab”). Springwater, and not Schwab, is your investment adviser and primary point of contact with respect to the SWIP Program. Springwater is solely responsible, and Schwab is not responsible, for determining the appropriateness of the SWIP Program for you, choosing a suitable investment strategy for your investment needs and goals, and managing your portfolio on an ongoing basis. Springwater has contracted with SPT to provide Springwater with the Platform, which consists of technology and related trading and account management services for the SWIP Program. The Platform enables Springwater to make the SWIP Program available to clients online and includes a system that automates certain key parts of its investment process (the “System”). The System also includes an automated investment engine through which Springwater manages your portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if your account is eligible and you elect this feature). Schwab ensures that the platform operates as described. The SWIP Program enrollment process includes a third-party questionnaire completed by you that helps us determine your investment risk profile. The results inform our recommendation for a suitable model portfolio. The recommendation is agreed to by you. The recommended model portfolios use low-cost, well-diversified mutual funds and exchange- traded funds offered by Dimensional Funds, Vanguard, Schwab, and others. Springwater charges clients a fee for our services as described below under Item 5, Fees and Compensation. Springwater’s fees are not set or supervised by Schwab. Springwater does not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at Schwab that are not enrolled in the SWIP Program. If Springwater does not meet this condition, then we may be required to pay Schwab an annual licensing fee of 0.10% of the value of our clients’ assets in the SWIP Program. This arrangement presents a conflict of interest, as it provides an incentive for Springwater to recommend that clients maintain their accounts at Schwab. Notwithstanding, Springwater may generally recommend to our clients that accounts be maintained at Schwab based on the considerations discussed in Item 12 below, which mitigate this conflict of interest. Springwater’s Chief Compliance Officer remains available to address this conflict of interest. Clients enrolled in the SWIP Program are limited in the universe of investment options available to them. For example, the SWIP Program investment options available are limited to ETFs and mutual funds, whereas Springwater may recommend various other types of securities in our other services. As a SWIP Program client you will have access to your account and a financial interface online but will also have the opportunity to consult with Springwater regarding your account. Please also refer to Item 8 below regarding the investment risks associated with mutual funds and ETFs. Rebalancing The System will rebalance your SWIP Program account periodically by generating instructions to Schwab to buy and sell shares of funds and depositing or withdrawing funds through the “Sweep Program”, based on your investment strategy and asset allocation. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an asset class varies by a set parameter established by us, (ii) we decide to change the funds or their percentage allocations for an investment strategy or (iii) we decide to change your investment strategy, which could occur, for example, when you make changes to your investment profile or impose or modify restrictions on the management of your account. Your account must have a balance of at least $5,000 for the System to rebalance. We review the performance of the SWIP Program platform regularly to ensure that our clients are invested according to the parameters of the model portfolios. Item 12 provides more information about the trading and execution functions of the SWIP Program. Sweep Program Each SWIP Program investment strategy includes a cash allocation (the “Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation is a minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen. The Cash Allocation is accomplished through enrollment in the Sweep Program, a program sponsored by Schwab. By enrolling in the SWIP Program, you consent to having the free credit balances in your account at Schwab swept into a deposit account (“Deposit Account”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC- insured depository institution that is a Schwab affiliate. The Sweep Program is a required feature of the SWIP Program. If the Deposit Account balance exceeds the Cash Allocation for your investment strategy, the excess over the rebalancing parameter will be used to purchase securities through rebalancing. If you request a cash withdrawal from your account, this may require the sale of fund positions in your account to bring your Cash Allocation in line with that for your target allocation. If you have a taxable account, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with Schwab, Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Compensation to Schwab Under the Program You do not pay fees to SPT or brokerage commissions or other fees to Schwab as part of the SWIP Program. However, Schwab receives other revenues including: (i) the profit earned by Charles Schwab Bank, a Schwab affiliate, on the allocation to the Sweep Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™, Schwab Funds® and Laudus Funds® that we may select to buy and hold in your account; (iii) fees received by Schwab from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in your account for services Schwab provides; and (iv) remuneration Schwab may receive from the market centers where it routes ETF trade orders for execution. Retirement Plans The investment advice and services provided by Springwater to our retirement plan clients vary, depending on each client’s specific goals, objectives and other unique circumstances. For retirement plan sponsors, our advice and services may include:  recommendations for the design of an appropriate qualified retirement plan;  the selection of suitable investment products to be made available to plan participants;  recommendations for the design of model portfolios to be made available to plan participants;  periodic review of the plan’s investment options, consultation regarding their continued suitability, and, if relevant, recommendations for alternative investment products;  periodic presentations to current and new plan participants addressing general plan design, investment choices and other plan features;  other services that Springwater and the client may agree upon. Trustee Directed Plans. Springwater may be engaged to provide discretionary investment advisory services to ERISA retirement plans, whereby Springwater shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Springwater will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Springwater will generally provide services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory Agreement between the Plan and Springwater. Participant Directed Retirement Plans. Springwater may also provide investment advisory and consulting services to participant directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement between Springwater and the plan. For such engagements, Springwater shall assist the Plan sponsor with the selection of an investment platform from which Plan participants shall make their respective investment choices (which may include investment strategies devised and managed by Springwater), and, to the extent engaged to do so, may also provide corresponding education to assist the participants with their decision making process. Client Retirement Plan Assets. If requested to do so, Springwater shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Springwater shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Springwater’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Springwater will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Springwater of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the Springwater to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Springwater calculating its advisory fee. Please Note: ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a participant or beneficiary of a Plan subject to Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets

in his or her Plan account or to take a distribution; (ii) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iii) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then Springwater represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by Springwater or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account. 4C. Client Tailored Relationships and Restrictions As a fiduciary, Springwater always acts solely in your best interest. Your portfolio investment strategy is customized and tailored to your unique circumstances, including your investment objectives, risk tolerance and capacity, and investment horizon. You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best interest cannot be honored and, if forced, may result in the termination of your advisory agreement. As part of our financial planning and wealth management services, Springwater may provide guidance regarding non- investment related matters. Neither Springwater nor any of its representatives serves as an attorney, accountant or insurance agent, and no portion of Springwater’s services should be construed as legal, tax or insurance advice. To the extent requested by a client, Springwater may recommend the services of other professionals for non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from us. Please note that if you engage any such recommended professional, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Please also note that it remains your responsibility to promptly notify Springwater if there is ever a change in your financial situation or investment objectives for the purpose of reviewing, evaluating and/or revising Springwater’s previous recommendations and/or services. 4D. Wrap Fee Program Springwater does not sponsor nor provide portfolio management services to a wrap fee program. 4E. Assets under Management (AUM) As of year-end 2023, Springwater managed $168,700,605 on behalf of our clients. $154,915,233 is managed on a discretionary basis, and $13,785,372 on a non-discretionary basis. In addition, Springwater had $15,686,575 of assets under advisement. 4F. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Springwater does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, Springwater does not prepare estate planning documents or tax returns, not does it sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance agents or brokers, etc.). The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Springwater and/or its representatives. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Note – Retirement Rollovers – Potential for Conflict of Interest. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Springwater recommends that a client roll over their retirement plan assets into an account to be managed by Springwater, such a recommendation creates a conflict of interest if Springwater will earn new (or increase its current) compensation as a result of the rollover. If Springwater recommends that you roll over their retirement plan assets into an account to be managed by Springwater, such a recommendation creates a conflict of interest if Springwater will earn new (or increase its current) compensation as a result of the rollover. Whether Springwater provides a recommendation as to whether a client should engage in a rollover or not, Springwater is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to rollover retirement plan assets to an account managed by Springwater. Springwater’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note – Use of Mutual and Exchange Traded Funds. Springwater utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Springwater’s investment advisory fee described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). Please Note – Use of DFA Mutual Funds: Springwater utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers. Thus, if the client was to terminate Springwater’s services, and not transition to another adviser who utilizes DFA funds, restrictions regarding additional purchases of, or reallocation among other, DFA funds will generally apply. Springwater’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above. Schwab. As discussed below at Item 12, when requested to recommend a broker-dealer/custodian for client accounts, Springwater generally recommends that Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge transaction fees for effecting securities transactions. In addition to Springwater’s investment advisory fee and transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). The fees charged by Schwab, or any broker-dealer/custodian directed by the client, are in addition to Springwater’s advisory fee referenced in Item 5 below. Please note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG). ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that maintain an acceptable ESG mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Springwater), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Springwater does not advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. Springwater generally relies on the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. WE DO NOT RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Springwater will advise the client to consider a potential investment in corresponding exchange-traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their prices are determined by the supply and demand of their markets. Because cryptocurrencies are currently considered to be a speculative investment, Springwater will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: Springwater does not recommend or advocate the purchase of, or investment in, cryptocurrencies. Springwater considers such an investment to be highly speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Reporting Services. Springwater can also provide, for a separate fee (see Item 5 below), account reporting services, which can incorporate client investment assets that are not part of the assets that Springwater manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other advisors that maintain trading authority, and not Springwater, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing, Springwater does not provide investment management, monitoring or implementation services for the Excluded Assets. The client can engage Springwater to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between Springwater and the client. Portfolio Activity. Springwater has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Springwater will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Springwater determines that changes to a client’s portfolio are neither necessary nor prudent. You remain subject to the fees described in Item 5 below during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Springwater will be profitable or equal any specific performance level(s). Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Springwater. Generally, with potential exceptions, Springwater does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by Springwater will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Springwater) will be profitable or equal any specific performance level(s)In addition, there may be other securities and/or accounts owned by the client for which the Registrant does not maintain custodian access and/or trading authority; and,
• hold other securities and/or own accounts for which Springwater does not maintain custodian access and/or trading authority. Corresponding Services/Fees: When agreed to by Springwater, Springwater shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4) report on such securities/accounts as part of regular reports that may be provided by Springwater; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Please Note: Non-Discretionary Service Limitations. Clients that wish to engage Springwater on a non-discretionary investment advisory basis must be willing to accept that Springwater cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Springwater would like to make a transaction(s) for a client's account (including in the event of an individual holding or general market correction), and the client is unavailable, Springwater will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Client Obligations. In performing our services, Springwater shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Springwater if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Springwater) will be profitable or equal any specific performance level(s). Cybersecurity Risk. The information technology systems and networks that Springwater and its third-party service providers use to provide services to Springwater’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Springwater’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Springwater are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Springwater has established its systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering that Springwater does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions Disclosure Brochure. A copy of Springwater’s written Brochure as set forth on Part 2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of an agreement between the client and Springwater.